Civil Rights

The Civil Rights Act of 1964 ended segregation in public places and banned employment discrimination on the basis of race, color, religion, sex, or national origin. It is considered one of the crowning legislative achievements of the civil rights movement. Its impact on transportation can be seen in how service is funded, designed, operated, and communicated to the general public, including people with disabilities. The initial act included twelve titles, each addressing a specific area. For example, Title VI prohibits discrimination by recipients of Federal financial assistance on the basis of race, color, and national origin, including the denial of meaningful access for limited English proficient (LEP) persons. RLS provides its clients with technical assistance regarding Title VI program development and implementation. RLS also provides such service in related areas, including the Americans with Disabilities Act, the FTA’s Disadvantaged Business Enterprise Program, and Equal Employment Opportunity requirements. In addition, RLS reviews all these areas as part of RLS’ Compliance Monitoring projects, which ensure that our clients achieve compliance with all applicable rules and requirements.

Americans With Disabilities Act (ADA)

Since the passage of Americans With Disabilities Act of 1990 (ADA) over 32 years ago, RLS & Associates, Inc. (RLS) continues to be recognized as an authority on ADA implementation and compliance, providing technical assistance and support to federal and state agencies, transit providers, and local communities to ensure that not only the law is enforced but that the spirit of ADA is carried out. To this end, RLS provides training, technical assistance, and regulatory reviews. Further, RLS staff has served as a Litigation Consultant to the U.S. Department of Justice, Disability Rights Section—providing technical assistance on ADA compliance and remedy. RLS has also developed, evaluated, and assisted in the implementation of Complementary Paratransit Plans for a number of transit systems and communities.

Disadvantaged Business Enterprise (DBE)

While not part of the Civil Rights Act of 1964, the Federal Transit Administration’s (FTA) Disadvantaged Business Enterprise (DBE) provides a vehicle for increasing participation from minority business enterprises (MBEs) in state and local procurement. For transit, that means ensuring that DBEs/MBEs are afforded the maximum opportunity to compete for federally funded contracts, exclusive of vehicle purchases. RLS has assisted state DOTs and local transit systems in the development of DBE Programs, including methodologies and goals.

Equal Employment Opportunity (EEO)

The Civil Rights Act of 1964 imposed Equal Employment Opportunity (EEO) requirements to ensure no individual would be denied access to employment on the basis of race, color, religion, sex, gender, or national origin. Compliance with these requirements focus on communication of an entity’s EEO compliance with the public via job notices, prospective employees through job applications, and existing employees via workplace notices and training. RLS has assisted clients with the development of each of these communication tools to ensure EEO compliance. RLS staff also review each of these components as part of on-site compliance monitoring reviews. RLS has worked directly with city and state officials and staff to develop new position descriptions, job postings, civil service tests, etc.

Limited English Proficient (LEP)

Each FTA subrecipient’s Title VI Program must assure meaningful access to its programs and services by individuals who are considered Limited English Proficient (LEP). This element of the Title VI Program has two main components: a Four Factor Analysis and a Language Assistance Program. This Title VI Program element can prove to be most challenging to both State DOTs and rural and small urban transit systems and is one area that RLS has provided a variety of assistance. For example, RLS conducts reviews to ensure that the Four Factor Analysis has been conducted properly including the identification of LEP individuals in the service area, determining the frequency with which these individuals come into contact with the program, and that sufficient outreach has made to LEP individuals. In addition, RLS has assisted clients with the development of a compliant Language Assistance Plan, in particular how the client monitors, evaluates, and updates the plan.

Title VI

Many Civil Rights requirements with which State DOTs and local transit systems must comply are included in Title VI (please see the summary for this subtopic). RLS assists State DOTs in the development, update, and on-going implementation of the state’s required Title VI program, reviewing subrecipient Title VI programs and policies, and ensuring Title VI compliance for all State subrecipients.

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